February 21, 2003
Mr. Jonathan G. Katz
Secretary
Securities and Exchange Commission
450 5th Street, NW
Washington, DC 20549-0609
Reference: File Number: SR-BSE-2002-15
Boston Stock Exchange, Inc.
Filing to Establish Trading Rules for the Boston Options
Exchange Facility
Dear Mr. Katz:
Please accept this letter on behalf of State Street Global Markets,
LLC ("SSGM") as a letter of support in favor of the Boston Options
Exchange ("BOX") facility.
SSGM, a wholly-owned subsidiary of State Street Corporation and an
affiliate of State Street Bank and Trust Company, is an SEC registered
broker-dealer and a member of the NASD and Boston Stock Exchange.
Currently, SSGM effects approximately 300-400 customer options
transactions per month on an agency basis. As a financial institution
with a customer base that consists of both institutional and retail
clients, SSGM continually strives to provide better execution quality
and transactional services to our customers at the lowest possible
costs.
SSGM, after thoroughly reviewing the model, strongly feels that the
BOX facility will be an improvement over the current floor based
exchanges in which options are currently traded. The BOX, just by its
open market structure, will assist SSGM in providing for better
quality executions for options trading. The unfettered and equal
access to the order book that provides for strict time/price priority
will allow all options trades to be executed at or better than the
NBBO. This feature, in the current environment that involves a great
focus on "best execution", will allow for greater execution quality
for customer trades. The full automation that includes straight
through processing of transactions and the minimal cost of entry will
provide for lower execution costs and create the opportunity for SSGM
to pass savings on to our customers.
In conclusion, based upon the factors mentioned above, SSGM is in
strong support of the BOX facility and feels that it will greatly
improve the marketplace for options trading. We greatly anticipate
the debut of this new alternative to the floor based exchange.
Best regards,
Nicholas Bonn
Executive Vice President
State Street Global Markets, LLC
617.664.4913
NB/dkc